Filing # 66284830 E-Filed 01/09/2018 11:39:20 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA0408003OOOM3AG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN individually, and J. individually, o SA C Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFEND MOTION TO STRIKE DEFENDANT/C EXPERT WITNESS, DR. BERNARD JAN Plaintiff/Counter-Defendant, Defendant/Counter-Plaintiff Bradl c Jansen, and to exclude the adtgfssroq Jeffity d. 'C l49 EY EPSTEIN'S -PLAINTIFF'S DAMAGES D TO EXCLUDE HIS TESTIMONY pstein wards' (S") ("Epstein"), moves to strike damages expert, Dr. Bernard is testimony because it does not assist the trier of fact, and states: Edtv • 4 D f (SIM A . i INTRODUCTION piing to Recover Damages Based on a Defamation Action estations to the contrary and this Court's rulings, damages used on a defamation action. plans to seek expert confinns this and has illustrated this in both statements made to the Court and in discovery: • March 24. 2011: In his Case Management Statement, informed the Court that, because he had to defend against Epstein's "spurious claims," he had to endure "the public embarrassment of having been branded as a participant in one of history's largest and most notorious Ponzi schemes." (D.E. 284, p. 2.) FILED: PALM BEACH COUNTY. FL. SHARON R BOCK. CLERK, 01/09/2018 11:39:20 AM EFTA02763669